his agency has noticed that several states have enacted laws to allow “multiple large-scale, privately-operated industrial marijuana cultivation centers.’’ And Cole said some of these could have revenues of millions of dollars a year “based on the planned cultivation of tens of thousands of cannabis plants.’’

“The (earlier) memo was never intended to shield such activities from federal enforcement action and prosecution, even where those activities purport to comply with state law,’’ Cole wrote. He said anyone in the business of cultivating, selling or distributing marijuana IS violating the federal Controlled Substances Act, “regardless of state law.’’

Potentially more significant, Cole said that also applies to those “who knowingly facilities such activities.’’